The Nature Conservancy comments on NOIRA for stormwater regulations
On behalf of The Nature Conservancy, please accept these comments regarding the notice of intended regulatory action (NOIRA) to amend the Virginia Stormwater Management Regulations. The Nature Conservancy has been involved with the development and public discussion of these regulations for the simple reason that stormwater poses a real and growing threat to the ecological and hydrological integrity of Virginia’s streams, rivers, and the Chesapeake Bay. These waters harbor significant biological diversity and provide an array of health, recreational, and economic benefits to citizens of the Commonwealth. We believe strongly that development and implementation of these regulations are critical to achieve Virginia’s water quality commitments and to ensure that Virginia can achieve the mutual goals of clean water and economic growth.
As decided by the Virginia Soil and Water Conservation Board (Board), the water quality criteria for the stormwater regulations will be reviewed based on the Virginia Total Maximum Daily Load Implementation Plan (TMDL) for the Chesapeake Bay Nutrient and Sediment TMDL. As the Board and the Department of Conservation and Recreation (Department) re-examine the regulations, The Nature Conservancy encourages all involved to acknowledge the tremendous amount of work that has been accomplished on this issue to date. We also submit that we are all best served if we focus our efforts on building on that body of work, which national stormwater experts have deemed technically and scientifically sound and a commendable approach to tackling what is an admittedly complicated issue.
We encourage the Department to initiate and proceed promptly with this regulatory action. The Nature Conservancy looks forward to continuing to work with the Board, the Department, and other stakeholders on this issue. Thank you for the opportunity to provide these comments.
